Belgium Fiscal & Treaty Framework
1. Bilateral Tax Accord & Jurisdictional Allocation (Belgium)
Relocating from Belgium to Spain activates the provisions of the Convention entre la Belgique et l'Espagne tendant à éviter les doubles impositions (1995). Under Article 15 of this bilateral accord, employment income is strictly allocated based on physical presence. If you move your tax residency from Belgium without electing the 24% Beckham Law regime via Form 149, the Spanish Tax Authority (AEAT) will subject your worldwide earnings to progressive Spanish income tax (IRPF) reaching up to 47% (and up to 54% in autonomous regions like Valencia).
By contrast, electing the Special Regime for Inbound Workers (Article 93 LIRPF) caps your Spanish employment tax at a flat 24% for active labor income up to €600,000 per year. Furthermore, foreign-sourced passive income (such as dividends, interest, or rental yield originating in Belgium) remains 100% EXEMPT from Spanish income tax.
2. Taxation of Belgian Stock Options (Law of 26 March 1999 taxation upon offer date), RSUs, and Warrants.
A critical area of divergence for executives from Belgium involves Belgian Stock Options (Law of 26 March 1999 taxation upon offer date), RSUs, and Warrants.. Under DGT Binding Ruling V0813-23, unvested equity grants are time-sliced across the vesting grant period: only the fraction of workdays physically performed on Spanish soil is added to your Spanish 24% taxable base.
Regarding corporate distributions, 15% Belgian Roerende Voorheffing / Précompte Mobilier withholding under Article 10. This provides significant cash flow protection compared to standard non-resident rates.
3. Statutory Departure & Compliance Requirements
Prior to relocating from Belgium, you must address local departure formalities: SPF Finances De-registration from Municipal Population Register (Model 8) prior to move. Transition from Belgian tax residency to Spanish Modelo 151 special non-resident status. Belgian VAPZ / IPT / Group Insurance pension capital payouts evaluated under Treaty Article 18.